9 July 2025

The Home Office published a new Statement of Changes in Immigration Rules (HC 997) on 1 July 2025 in connection with details outlined in the Government’s Immigration White Paper. The Statement of Changes introduces seismic changes to UK immigration and the sponsorship landscape. You can read our breakdown of the main changes here.

Several of the most significant changes are due to be implemented imminently, with most taking effect for Certificate of Sponsorships (CoS) assigned on or after 22 July 2025. We therefore summarise below what sponsors could be doing to prepare for the deadline, ensure compliance and take advantage of the more favourable provisions which are currently in place (and any transitionary provisions which may continue for some in this cohort when submitting a further application in future).

Some of the key changes which are likely to significantly impact workforce planning for a business are:

• Skilled Worker skill level increase – the minimum skill requirement under the Skilled Worker route will rise to degree level (RQF level 6) thereby removing around 180 previously eligible roles
• Skilled Worker salary threshold increase – the general salary threshold will rise to £41,700 and the associated occupation code ‘going rates’ will rise in line with this
• Global Business Mobility: Senior or Specialist Worker – the skill level will be unaffected (as this is already set at RQF level 6) however the salary threshold will rise to £52,500 and the associated going rates shall also increase.

Despite these restrictive measures coming into force soon, it may still be possible for certain roles which do not meet the above requirements to be eligible for sponsorship, for instance if they are on the new ‘Temporary Shortage List’, if any other exception applies or if some transitional arrangements apply. However, individuals sponsored on the ‘Temporary Shortage List’ would not be able to bring family members, will be restricted in terms of supplementary employment, and in the future, their company will be required to demonstrate compliance with a sector workforce plan. You can read more about these upcoming restrictions in our article.

What employers can do to prepare for the upcoming changes to the Immigration Rules

In the first instance, it would be advisable for employers to audit all Skilled Worker applications which are currently in progress and any which may require sponsorship over the coming months, to determine whether affected roles meet the new skill and salary requirements.

Where possible, sponsors should assign CoS before 22 July 2025 to ensure that they and the affected individuals are able to rely on the current more favourable provisions. Given that CoS must be used (ie an application for entry clearance or permission to stay must be submitted) within three months of the date on which they are assigned, and individuals can apply up to three months before their start date, a CoS can be assigned now to an individual with a start date in six months’ time. It would therefore be prudent for sponsors to consider sponsorship needs in the medium term and consider working on the matters now, in addition to extant or immediately upcoming applications.

It follows that sponsors may also wish to assess their current CoS allocation to ensure they have sufficient Undefined Skilled Worker CoS to be assigned prior to 22 July 2025, particularly if they are wishing to bring forward application submission dates.

In summary, the imminence of the changes may mean that sponsors should urgently consider the implications and prioritise any steps which can be taken to minimise the negative impacts on their businesses.

Get in touch

Please contact enquiries@lauradevine.com or your assigned LDI lawyer if you would like further assistance to prepare for these upcoming changes and subscribe to our mailing list to receive the latest updates and implementation timelines as they become available.